United States v. Woodall, No. 14-2704 (8th Cir. 2015)
Annotate this CaseIn 2001, Woodall was convicted of in Missouri for having sexual relations with his 15-year-old stepsister. He was required to register as a sex offender. In November 2012, Woodall moved to Iowa but did not notify Missouri authorities or register in Iowa, as required by the Sex Offender Registration and Notification Act, 42 U.S.C. 16901. Woodall pleaded guilty, 18 U.S.C. 2250(a). A presentence report found that Woodall "consumed marijuana once every other month" and described himself as a "social drinker, consuming one or two beers each month." Woodall had been terminated from a sex offender treatment program in 2007, during a previous incarceration, when he got into a fight and attempted to commit suicide in 2014, leaving a note that was potentially threatening to U.S. Marshals. Woodall was diagnosed with major depressive disorder and potential adult attention deficit disorder. The district court sentenced Woodall to 10 months, the bottom of the Guidelines range, and imposed five years of supervised release with conditions prohibiting use of alcohol; entering bars, or other establishments whose primary source of income is derived from the sale of alcohol; and contact with children without the prior written consent. The Eighth Circuit vacated the condition relating to alcohol.
Court Description: Criminal case - Sentencing. In this SORNA conviction, the district court erred in imposing a special condition in defendant's supervised release which prohibited from consuming alcohol or going to bars as the district court's condition relied predominantly on a factual conclusion of drug dependency without linking it to another factor such as mental health; the court did not err in imposing a special condition barring unapproved contact with minors as defendant had a serious sex offense conviction and his failure to register as a sex offender and his failure to complete a prescribed sex offender treatment program were directly related to potential recidivism.
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